ML22140A232
| ML22140A232 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/2022 |
| From: | NRC/OCM |
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| Download: ML22140A232 (71) | |
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UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
+ + + + +
34TH REGULATORY INFORMATION CONFERENCE (RIC)
+ + + + +
TECHNICAL SESSION - TH25
PRACTICAL EXPERIENCE IN EXECUTING A 10 CFR PART 52
COMBINED LICENSE FOR VOGTLE UNITS 3 AND 4
+ + + + +
THURSDAY,
MARCH 10, 2022
+ + + + +
The Technical Session met via Video-
Teleconference, at 8:30 a.m. EST, Omar
Lopez-Santiago, Deputy Director, Division of
Construction Oversight, Nuclear Regulatory
Commission, presiding.
PRESENT:
OMAR LOPEZ-SANTIAGO, Deputy Director, Division of
Construction Oversight, RII/NRC
ZACH HARPER, Manager, Plant Licensing Engineering,
Westinghouse Electric Company, LLC
AMY CHAMBERLAIN, Nuclear Development Regulatory
Affairs, Southern Nuclear Operating Company NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 2
NICOLE COOVERT, Chief, Construction Inspection
Branch I, Division of Construction Oversight,
RII/NRC
VICTOR HALL, Chief, Vogtle Licensing & ITAAC
Branch, Vogtle Project Office, NRR/NRC
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 3
P R O C E E D I N G S
(8:30 a.m.)
MR. LOPEZ-SANTIAGO: Good day and welcome
to the third day of the 2022 Regulatory Information
Conference, or the RIC. This morning, we're going to
have a great panel of discussion about our experience
executing the first Part 52 Combined License for
Vogtle Units 3 and 4.
My name is Omar Lopez-Santiago. And I'm
the Deputy Director for the Division of Construction
Oversight in our Region II Office in Atlanta,
I'm going to be the Chair for today's
panel discussion. This is a busy time for Vogtle and
all of us as we work together to ensure that the first
new powerplants built in this country in over ten
years are safe.
We meet today, we have the following
panelists: first, Zachary Harper. Zach is the
Manager of Westinghouse Plant Licensing Engineering
team and his group is responsible for Westinghouse
Licensing Activities related to new plant builds.
Next we have Amy Chamberlain. Amy is the
Nuclear Development Regulatory Affairs Manager for
Southern Nuclear. In this role, Amy supports Vogtle NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 4
3 and 4 construction licensing needs.
Next we have Nicole Coovert. Nicole is
the Branch Chief of the Construction Inspection
Branch 1 in DCO in the same division I work for and
Nicole is responsible for managing the construction
inspection program of Vogtle's Units 3 and 4.
And last but not least, Victor Hall. Vic
is the Branch Chief of the Vogtle Project Office at
the Office of Nuclear Regulatory Regulations. Sorry,
Nuclear Reactor Regulations, NRR and he's responsible
for licensing and overseeing the construction of
Vogtle 3 and 4.
In today's panel, we're going to be
discussing the following topics: We're going to be
talking about licensing, ITAAC and you are going to
hear that word a lot, ITAAC means Inspections Tests
Analysis and Acceptance Criteria.
The construction inspection program and
applying lessons that we have learned throughout this
process to future applications. As a reminder, this
is a panel discussion so we encourage everybody, the
audience, to ask questions to the panelists and
please use the chat function in the application.
So as an introduction and a start to
kicking off the panel discussion, please Vic, tell us NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 5
a little bit about your work with Part 52.
MR. HALL: Thanks Omar. And welcome to
everyone to the Regulatory Information Conference.
So in Part 52, I won the Part 52 lottery and it's the
jackpot because I have the best job in the world.
What I mean by that is the work that we
get to do is so unique and so important to the country
that again I feel incredibly blessed and lucky to do
what I do.
So I'm the Branch Chief of the Vogtle
Project Office in the Office of Nuclear Reactor
Regulation. I love our tag line. In NRR, it's we
make the safe use of nuclear technology possible.
And as you might have gleaned from the
name Vogtle Project Office, we do that very
specifically for the Vogtle Construction Project
which is as Omar mentioned, the first nuclear
construction project in this country in over 30
years.
So this is going to sound really corny.
I want to apologize, but it's like 8:30 in the morning
here in D.C. and I'm the king of bad jokes, but what
we do in the office is kind of magic. It's making
safety from nothing.
As a regulator, you know, we don't make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 6
a single pump or a valve, we don't design anything,
we leave that to Zach and the good folks at
Westinghouse. We don't build the plant, we leave
that to Amy and the fine folks at Southern.
But what Nicole and I get to do is from
paper. We help create the rules, we inspect, we do,
you know, we don't create anything, but we make
safety.
We're able to create the plant, make the
plant safe through our regulatory structure through
our licensing and through our oversight which we do
at VPO.
And that's kind of a cool thing when you
think about it, it's an influential pursuit of making
something safe without actually touching it. And so
it's a kind of a unique thing. And it takes
incredibly talented folks to do that.
There's a skill, there is a special
knowledge that goes into being a regulator and making
that happen. And that's where I feel perfectly lucky
because I'm working with the folks in the Vogtle
project office who are just really good at what they
do.
We have, there are 11 of us, we are
engineers, project managers, who have since the very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 7
beginning of Part 52 worked on this unique process to
make and make the plant safe. Part 52 is kind of a
unique beast.
It's the first time we're ever going
through this process. If you've heard me talk about
Part 50 in the past, you know, it was derived from
the FCC's regulations on building communications
tower.
There was a separate construction permit
for building them and then operating them. So, you
know, you're talking about 1950s type regulatory
structure. And Part 52 which is born in the 1990s
was meant to standardize plants, bring some stability
to the very first structure, and you know, we now
have 20 years' experience of design certifications,
combined licenses and a lot of lessons learned from
that.
And we're in the first kind of stages of
this overseeing construction to the very end which is
really exciting in getting to see all of that come
together.
So in terms of Part 52, my experience is
the last four years working with incredible people
who have incredible experience and getting a chance
to see this plant come out of the ground and be done NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 8
safely.
MR. LOPEZ-SANTIAGO: Okay, great.
Nicole, what about you?
MS. COOVERT: Good morning. As Omar said,
I am, my name is Nicole Coovert. I am the Branch
Chief in the Division of Construction Oversight in
the DCO Region II Office. And I would echo Vic Hall
that the folks that I have the pleasure and
opportunity to work with every day are just
incredible inspectors with skill sets that go across
many different disciplines and experiences.
And when I say inspectors, it's Region II
inspectors. All of us are involved in the Vogtle
project and performing inspections. So it's part of
our mission. We regulate and provide inspection
oversight.
Other construction activities for the
Vogtle Unit 3 and 4 sites that's located in
Waynesboro, Georgia. And this is to provide
reasonable assurance of adequate protection for
public health and safety to promote common defense
and security and to protect the environment.
The Division of Construction Oversight
also implements the inspection program which includes
resident and regional inspectors with the support NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 9
from headquarters technical experts as Vic Hall was
referring to.
And what keeps us busy, very busy, is the
planning, scheduling and completing of three
different types of inspections which are construction
inspections, initial test programs, and operational
program inspections.
The resident and regional inspectors at
Vogtle exert significant time and resources to verify
that the licensee's construction and completion of
inspections, tests, analyses, and acceptance criteria
deserve more say and we'll say that a lot today, is
what we call ITAAC.
As part of the new reactor licensing
process for the licensee of Part 52, a combined
license enables the licensee to construct a plant and
operate it once construction is complete.
And if certain design-specific pre-
approved sets of performance standards, or ITAAC,
identified in a combined license are satisfied. So
essentially, the ITAAC or necessary information, that
when successfully completed by the licensee, provide
reasonable assurance that the facility has been
constructed and will operate in accordance with the
combined license, the provisions of the Atomic Energy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 10
Act of 1954 as Amended and the NRC's rules and
regulations.
So through licensing and inspection
activities, when the NRC makes that determination
that all ITAAC is satisfied, the NRC would authorize
licensee to load fuel, initial plant startup, an
operation which we also commonly call and refer to as
the 52-103G finding.
MR. LOPEZ-SANTIAGO: Thank you, Nicole.
Amy, your turn.
MS. CHAMBERLAIN: Sure. I'm Amy
Chamberlain. I'm the Nuclear Development Licensing
Manager for Southern Nuclear. And I have actually
spent most of my career working in Part 52.
The last eight years I've been here with
Southern working to build the Vogtle 3 and 4 plants
in Augusta, Georgia. My team is based out of our
Birmingham office so we are responsible for license
amendments, exemption requests, alternatives, and
really being the forward-looking organization to take
some of that work off of the folks at the site.
And so for the last eight years we've
been working very closely with Westinghouse and
Zach's team to process these license amendments and
various changes to our license.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 11
So but before I came to Southern, I also
have worked in other Part 52 applications and pre-
applications. So I've seen Vogtle 3 and 4 actually
get constructed and getting really, really close to
coming aligned.
It's really personally for me something
I wanted to see for our industry. So I'm really
excited, like you said, it's a very busy time at the
site. And we're working hard to get those ITAAC
closed. So that's my role for Part 52.
MR. LOPEZ-SANTIAGO: Thank you, Amy.
Zach, what about you?
MR. HARPER: Good morning, everyone. My
name is Zach Harper. I'm the Manager of Licensing
Engineering here at Westinghouse. I have about 12
years of experience working in Part 52.
I started when we were still developing
the design certification document. And my experience
there was primarily working in the ISG 11 process
which now is in RG 1.206 and supporting the ACRS
meetings and the various chapters, the responses to
the NRC's Request for Information.
I also supported the different license
applications for AP1000 and as well as I've also
supported some international efforts in China, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 12
supporting their licensing process as well.
Since the design certification timeframe,
I've been supporting Amy and her team to develop
inputs to their license permit amendment requests and
the Tier 2 departures, that are written under the
Section 8(b)(5)(B) criteria as well as supporting the
site teams with ITAAC closure via engineering inputs.
I have a pretty unique job where I get to
sit between the Westinghouse engineering team that
defines the requirements and specifies the design for
the plant.
I also work with the construction
engineers on site to make sure that, you know, we
understand their needs and how, what we can do within
the bounds of license to make their job easier and
more efficient.
And then working with the team, the ITAAC
team there on site to understand where they're
struggling or in need of changes or clarification on
requirements or what design inputs they need for
ITAAC closure.
I'm excited to be with you today. I look
forward to the questions that we can answer.
MR. LOPEZ-SANTIAGO: Thank you,
everybody. So let's start with licensing. And this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 13
question is for Amy. Amy, from your license
perspective, what do you perceive to be the greatest
benefit to executing a Part 52 combined operating
license?
MS. CHAMBERLAIN: So I would say it's two
parts and they're kind of intertwined, certainty and
finality. So those, so certainty and what has been
designed has been licensed and constructed in the
Part 52 process.
We're required to construct in accordance
with our license and I will say during construction,
this always, this hasn't always been a benefit and it
sometimes has been a challenge, but I personally
believe that when we become operational, we'll have
certainty in our licensing basis through the work
that we have done as a licensee through the various
processes including ITAAC.
And finality plays into that certainty.
We have, the DCD has finality and that through the
process has gained a certainty in the construction
process also. I don't know, Zach, you want to chime
in on finality and the DCD?
MR. HARPER: Yes, I think that that's
really one of the key advantages of, you know, the
Part 52 process where you get that finality and you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 14
get those safety issues identified and resolved up
front in the process and resolved.
And then through the COL application that
designs application process, that design has finality
and that goes up through the start of the plant.
I would say that, you know, just to jump
off of the question that you have, another key benefit
of the Part 52 process is standardization.
You know, for me, I perceive, you know,
the Part 52 process, you know, the key advantages is
standardization, design finality, resolving those key
issues up front prior to construction.
So for, you know, the key success for, of
a new nuclear build, you know, standardized design
developed through a standard procurement and
construction process and is licensed in a standard
approach and it's perhaps the most salient lesson
learned from, you know, the 1980s of their nuclear
builds.
And it was recognized through the
development of the Utility Requirements Document, the
URD and the promulgation of the Part 52 and allowing
that standardization and the finality of it really
gives a designer and a licensee the confidence to
know that once that plant is constructed that it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 15
going to start up and operate.
MR. LOPEZ-SANTIAGO: Okay. Vic, this
question is for you. How has the NRC managed to cut
license amendment review times in half compared to
the review times for the operating fleet? Can you
apply that for all licensing work done by the NRC?
MR. HALL: Thanks, Omar. So I'm going to
give a little background and context. Because as Amy
mentioned, there have been a fair number of licensing
actions since the combined licensing from 2012.
We have, the NRC has issued and posted
just over 200 licensing actions which includes
license amendments, examinations and code
alternatives and the last four years really since the
formation of office bubble project office and another
group we'll talk about called the Vogtle Readiness
Group, the VRG.
We managed to keep our review time around
six months which is about half of the standard time
for a, I'll call it a routine licensing action inside
the Agency and the most important thing is we've done
it with the same come and high rigorous standard of
safety.
So there, you know, it's not like we're
just doing them quicker. It's still, it's a matter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 16
of being finding efficiencies and doing things kind
of to the pace it's required for construction
because, you know, what's different about Vogtle
obviously to the rest of the fleet is they're building
a plant and there's a need to change the license as
things come up as construction is showing that the
plant designs will be a little bit different than
what we originally anticipated.
So how we've gotten there, you know, the
first thing is we have amazing people working on this.
The Project Managers that we have on our team are
extremely experienced in Part 52 and new reactors.
They're problem solvers. And so they
know their craft. And then again, it is a craft to
be an NRC Project Manager that knows the regulation,
that understands the engineering side of it and can
bring those two together towards safety.
So we have amazing people that work on
this who are currently motivated. And really I'm
going to say a huge tip of the hat to communications
that we've done for this project.
I mentioned the Vogtle Readiness Group.
It's kind of, we took our lessons learned from the
watts bar reactivation and built this, I'll call it
a team.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 17
But really it was still our independent
parts of our agency working together and just
communicating nonstop. We've had, I think 40
different VRG meetings in the last four years.
And it's really just bringing together
different parts of the Agency. The Vogtle project
office chairs part of it, Nicole's group and Omar,
your group obviously in the did the new construction
oversight and Region II chair it.
And we have other support from NRR. And
we bring together all the different parts of the
agency. We bring together our tech groups. We bring
together our legal side.
We bring together our security folks, our
IP folks and we have discussions about what's coming,
and how we can solve the problems in front of us. So
that's internally. Externally, we've been meeting
with the licensee and with all our stakeholders very
frequently to make sure that we see problems, or see
the questions that are coming up ahead of time and
set ourselves up for success.
We set up a cadence of weekly public
meetings for licensing actions. You know, our teams
are probably going to be required to face off, you
know, having close to 10 to 12 licensing actions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 18
inhouse at a time. Right?
And so those weekly meetings were really
key for us to be able to talk about the issues that
were in front of us and talk about the challenges.
A lot of pre-application engagement so
those meetings were fantastic to be able to get a
feel for what was coming. And quite frankly, again,
it's been thanks to those types of communications
that the qual of the applications that have come in
from Southern had a good and put a lot of state to
complete our views in shorter times.
So I think it's been just communications,
communications, communications that they've really
allowed us to move at a faster pace than typical.
If you guys are fair for me, Omar, to say
the rest of the Agency should just communicate and
yes, fix it all. It's a completely different set of
challenges and different scale that we've been
working on, but I do, I am very proud of the work
that we have done at the Agency in licensing.
I do think there are lots of really good
lessons learned. We'll talk about lessons learned,
there's lots of positives we can draw from the work
we've done on licensing and again help build our
efficiency in that place as we go forward.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 19
MS. CHAMBERLAIN: I --
MR. LOPEZ-SANTIAGO: Okay, thank you. Go
ahead, Amy.
MS. CHAMBERLAIN: Yes, if I could just
jump off of that. I, you know, the communications
have been key, but it's been kind of specific and one
of the things we did a number of years back was talk,
work with NRC to define what we say are high, low and
medium complexity bars.
So we knew, Zach and I knew going in what
bars we thought were high complexity just based on
the amount of engineering work involved or the
internal churn on creating the arguments of why we
needed the license amendment.
And so extending that, those lessons
learned that we have learned internally between our
two organizations and opening up that line of
communication with the NRC, so that we were
communicating, hey, this one's coming in, this
licensing action is coming in and we think it's medium
complexity because of X, Y and Z.
It really helped the staff prepare for
those pre-application meetings so that they had the
right folks in the room for those meetings. And then,
down the road they could plan, okay, this one is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 20
very high complex bar.
We are most likely going to need an audit
of this work and we would have all of that planned in
advance before we even submitted the licensing
action.
So I think that was key, but then also on
the other end because, you know, we're nuclear. We're
always learning, we're always trying to get to
excellence. We took a lot of feedback from the early
days as submitting these licensing actions and really
worked them in to submittals.
Each time we learned, we learned
something that hey, we expect the staff to ask this
question and so making sure we had it up front in the
signals and one interesting thing I love data.
And you could see from our submittals if
you look in ADAMS at the number of RAIs. They really
decrease over time as we got better with that
communication.
So and as Vic said, just because I like
numbers, we actually have somewhere around 15
exemptions and alternatives today. And we're
currently on amendment 188 for Unit 3 and 186 for
Unit 4.
MR. LOPEZ-SANTIAGO: Okay, we got a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 21
question for Vic. Vic, why are many advanced reactors
designers not taking advantage of Part 52 and instead
opting for Part 50?
MR. HALL: Yes, great question. And I
listened in to some of, I think it was Tuesday's
session on advance reactors. And heard, I think it
was the folks at X-energy talking about looking at
using Part 50. You know, my guess, again, this is a
guess because I think we're kind of focused on the
back end construction, but if you look at going way
back to what it takes to get a certified design and
a COL, I imagine there's some calculations that go
back to how much it's going to cost for that delible
work so, you know, we're, the NRC is developing a
Part 53 which is going to be a technology neutral
framework which I know just about, you know, this
much about.
But that might be the future for advanced
and smaller reactors. I think Part 50 and Part 52
are still the standard for a large light water nuclear
reactor.
So if you're looking at a smaller plant,
small modular plant, you know, I don't know how to
tell enough to put together. So it's a fair question,
it's probably better directed at those designers who NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 22
are looking at advanced reactors.
And I think it's going to take into the
totality of the process. At the very beginning, if
you look back at Zach when you start, when Zach
initially submitted the D.C. for Westinghouse, we're
talking gosh, 2000, I'm going to mess up my math here,
2002 timeframe is when you first applied I think for
the D.C. AP1000.
So you're looking at a long stem between
that and where we are now. I think the some shows
going through it.
MR. LOPEZ-SANTIAGO: Okay. So let's move
on to ITAAC for a little bit and then we might go
back. We might come back to licensing. So Nicole,
what preparation was required for complex ITAAC such
as structural reconciliation, the ASME ITAACs or
long-lead items?
How has the NRC been inspecting ITAAC and
how does that relate to the 103G finding?
MS. COOVERT: Oh, thanks, Omar. Well,
first of all, you know, complex long-lead ITAAC, you
know, as you said, one of the examples is the ASME
related systems like reactor coolant system or the
passive core cooling system.
You know, for our inspections, we verify NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 23
that the systems were designed, constructed,
fabricated, installed, and tested to the required
codes and standards.
For these long lead ITAACs, the NRC has
been inspecting these activities since the beginning
of the construction projects and as we're approaching
Unit 3 all ITAAC complete milestone, we actually had
relatively minimal inspections remaining compared to
the amount of inspections that we've already
completed.
So to give you understanding of our
inspection process for these complex ITAAC, so early
on in the construction project, the NRC performed
vendor inspections and observed the initial
fabrication and construction in our key AP1000
components all over the world.
A couple of examples is the inspected
major reactor coolant system components and
containment fabrication in Japan, Korea, Italy. We
have our inspectors out there at these facilities
performing those inspections.
We inspected safety related, key
electrical component fabrication in Switzerland. We
also went to the Wyle Labs (inaudible) in the United
States to observe squib value testing and we observed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 24
fabrication of modules, mechanical skids, ASME system
piping assemblies, at multiple different vendors.
So following that, the NRC will also
perform multiple design specification inspections at
the design authority, Westinghouse.
And Zach was present for I would say most
of those inspections in the corporate office. And
this was to verify that the design of this key AP1000
component system structures would meet the acceptance
criteria and that the design ensured that the most
probable transients, the most probable occurrences
that would occur during normal operation and
operational transients would have least radiological
risk and those with extreme situations have the
potential for the greatest risk are the least likely
to occur.
And essentially, that is the licensees
accident analyses that is described in their Updated
Final Safety Analysis Report. And from there, the
NRC inspection staff who performed installation
inspections at the Vogtle site will verify that the
license was constructed, welded and performed non-
destructive testing for ASME systems, in accordance
with applicable code.
You know, other inspection attributes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 25
included verifying welder welders were qualified,
construction activities were reviewed and approved by
authorized nuclear inspectors as required and then
our final aspect inspections verify that the as-built
conditions meet the design and if they don't how are
they reconciled.
These inspections, they include pre-
operational component and system testing like
verifying a flow rate or system functionality as
designed, or performing components or system
walkdowns to verify compliance with seismic,
equipment reliability in harsh environments like high
pressure, temperature, moisture such that the
component/system would perform its intended function
during a design basis accident.
So to better inform and prepare our
inspectors for these tests, including start-up
testing, the NRC and the Chinese regulator, National
Nuclear Security Association, or NNSA, participated
in an inspector exchange program that lasted several
years and allowed approximately 18 NRC inspectors to
travel to China to Sanmen nuclear power plants and
witness first hand some of these activities.
Additionally we were able to engage with
Southern Nuclear and Westinghouse staff at Sanmen and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 26
that helped us to get an understanding of the
differences or the changes that we would see in the
U.S. AP1000 plants.
So definitely, as I describe it, it's a
very complicated for these long-lead inspection
program for some of these ITAAC and it's happened
over the years.
And so as Amy had said and Vic had said,
one of the most important key lessons learned is to
communicate and communicate often. Some of these
other activities like the structural reconciliation
and that is to verify the seismic category Class 1
structures like a containment shield building.
You know, they didn't have the formal
structure, the documentation structure like ASME Code
does in the system N5s so we met with Zach and
Westinghouse and Southern Company years ago to
determine what those final documents would look like.
So all of these things are planned in
advance. So lessons learned is for complicated long-
lead activities whether it's non-ITAAC or ITAAC, it
is very important to understand what the end product
looks like so that you can plan it and be prepared
for those complicated issues. Thanks, Omar.
MR. LOPEZ-SANTIAGO: Thank you, Nicole.
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So this question is for Zach. Zach, do you have any
lessons learned about the easiness of it to inspect
MR. HARPER: Yes. So I would just maybe
leverage a little bit off of Nicole's response. She
was talking about the lessons learned related to the
planning activities.
I think for us one of the key lessons in
terms of inspectibility for those long lead type
ITAAC or the ITAAC that we were having to perform
very early in the project, was we had, I would say an
area of struggle where Westinghouse did not
necessarily appreciate what a targeted ITAAC meant.
Where, you know, we would have activities
such as EQ or ASME and, you know, the NRC had
identified those to be inspected, but those
activities for example were already complete.
So you know, for us, you know, us thinking
okay, targeted ITAAC inspection, we will provide all
of the documentation at the end. I think one of the
lessons there for us was, okay, when they say target
it, we'll make sure that, you know, they're, we have
to plan that out, make sure that they're on site at
the vendor at Westinghouse.
Most of the remaining target ITAACs are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 28
on site so it's not as applicable right now, but when
we had first started, it was I would say taxing on
both Westinghouse and the NRC to make sure that to
catch up and identify, okay, how can we satisfy the
ITAAC and make sure that we had a good understanding
of what needs to be completed.
So I would say that was one lesson learned
for us. Another would be an area that for
inspectibility, where there's not a basis document
for an ITAAC, like what you would have for a tech
spec so we really never go back and forth on what
tech specs mean because there's a basis, there's
analyses that they describe exactly what the
intention of that tech spec is.
There's not for an ITAAC and so I think
the lesson for us was, okay, for ITAAC that, because
you, ITAAC really just have a very basic statement.
They have a design commitment test and
then an acceptance criteria and, in some cases, that
can be taken different ways. So I think clear
communication between Westinghouse and Southern and
Southern and the NRC on how that ITAAC will be
completed and the documentation that will be provided
as an important part of the inspectibilty for an
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Another example would be during testing
such as hot functional testing where hot functional
testing is a very dynamic evolution where a lot of
tests are happening.
It's a very coordinated event where the
site, where the plant heats up, tests are performed,
and then the plant cools back down. So for us,
something that we had learned in China that we had
applied here in the U.S. was to establish predictive
analyses prior to that hot functional testing.
That way the, you know, when the test is
run, Westinghouse can do a quick post-test analysis,
confirm that the ITAAC, yes, the ITAAC can be met and
then move on to the next test.
And then the ITAAC paperwork can be
verified later. And then having a good understanding
between Westinghouse and Southern and if it's
targeted, the NRC up front will look at what we
planned to do.
But I think that's an area that I would
say was a success, is having that good plan
established, having those predictive analyses already
run that way we knew that we met the ITAAC whenever
we did our post-test analysis and we could just move
on to the next test and not have any delays.
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MR. LOPEZ-SANTIAGO: Thank you, Zach.
Amy, do you have anything to add?
MS. CHAMBERLAIN: Yes, I'll just echo
Nicole and Zach, you know, that, I mean, that
overcommunication especially with the dynamic
construction situation ensuring that the staff
inspectors have access to see what they need to see
to inspect is critical.
And then on the ITAAC language itself,
verbatim compliance, I'll just say a little less than
half of all the licensing actions we've submitted
were ITAAC related.
We need to make some sort of change so
that verbatim compliance, I think that's a lesson
learned. It was for us, we learned while we went,
but also for future applications, making sure that
you're very clear on that language so that it can be
inspected.
And then, you know, as Zach said, there's
no basis documents so there's certain words that you
would think we all understood what they meant, but
there's a lack of definition of them.
And so I would say that ensuring that
those specific words like as built were in your
licensing basis and your Tier I and your COL could NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 31
really help a future applicant so that everybody is
on the same page with ITAAC.
MR. LOPEZ-SANTIAGO: Thank you. So this
question is for Zach. And it's a little bit long so
I'm going to, bear with me here. So the China AP1000
project, even as a first of kind plant, were finished
in about eight years and have already been
operational for a few years.
But it is already more than 10 years for
the construction of Vogtle Units 3 and 4 which have
been delayed again and again. From your perspective,
what are the reasons for the delays for the Vogtle
project? Were any lessons learned from the China
AP1000 products used to help the Vogtle project?
MR. HARPER: Okay, all right. So I think
just as a little bit of background, so there are four
AP1000 plants that are operating safely in China.
China uses a Part 50 type process where
it's kind of like a modified type 50 process where
they have a PCR that's required to obtain a
construction permit for the AP1000 that have been in
around in the 2009 timeframe.
Then they construct and to load fuel they
submit an FSAR, a Final Safety Analysis Report, to
the China National Nuclear Safety Administration, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 32
NNSA, and then something that's a little bit
different than Part 50, they have something called an
RFSAR which is a Revised Safety Report which they
submit about a year after initial operation.
And the plants, the plants have been
operating safely in the United States for quite some,
or have been operating in China for a few years now
and they're performing very well.
The, in terms of a comparison between a,
this is really a comparison of a Part 50 to a Part 52
process, so I don't think that the delays either in
China or here in the U.S. were resolved of the
regulatory process. The regulatory process is
robust.
It can be trying at times no matter what
process you follow. I don't think we're necessarily
victims of a Part 52 process. I don't necessarily
agree with that part of the comment.
I think the, in terms of lessons learned,
yes, there were a lot of lessons learned that were
brought from the China projects to the U.S. Some
examples were for, you know, we for the first of a
kind testing where the design certification has a
subset of tests that were identified as being special
where they, where these tests are really there to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 33
demonstrate phenomena of the plant acting, make sure
that the phenomena of the plant is performing as
expected.
These are tests like natural circulation
tests. There's the in containment reflow and water
storage tank test, heat up test, so on and so forth.
So those tests were run in China and we
were able to demonstrate that the plants were the
same build in China as here in the U.S. And we were
able to successfully write license amendment requests
to take advantages of those tests and show that the
performance in the United States would be the same as
the performance here, or the performance in China.
So that was one example. Another example
or you know, detail design changes that are
identified since they're and it's the advantages of
standardization where it's a standard design.
They have the same plan, well, same
nuclear island in China as they do here. Their
turbine building is a little bit larger because of
the different standards, but you know, those design
changes we, as they are developed for China, they're
reviewed for applicability and if they're good
changes to be made, they roll right into the design
for the U.S. plants.
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So that's a very, it's an active process.
It's ongoing as the plants are built and constructed
there. So I think I'll pause there. If there's more
questions later, we can address more.
MR. LOPEZ-SANTIAGO: Okay, thank you,
Zach. We have a question for Amy. Amy, regarding
documentation of ITAAC, there was a lot of
preparation including table top and exercise on how
to close ITAAC.
Still it seems that closure
recommendation for the final ITAAC appears to have
encountered significant problem at the last moment
holding up the 103g finding. What went wrong and
what lessons are there for future Part 52 applicants?
MS. CHAMBERLAIN: So we've mentioned that
we've been working the close, as the comment
suggests, we're working to close ITAAC basically
since the beginning of the project.
And you know what we see in the ICN
submittals, are a list of reference to principle
closure documents. And at times, these can be a lot,
hundreds of documents that go in, that are referenced
in a single principle closure document.
And so for many of the ITAAC that are
left, there are significant portions of them that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 35
already completed. But as the comment mentions,
there is documentation that still needs to be
completed.
And we do hold ourselves to a very high
standard. We want to complete this plant in a safe
and quality way and so we've got to get the
documentation right.
And the documentation comes after
construction is complete so that's where you would
see so why we haven't submitted all of the ICNs for
Vogtle 3 and 4 at this point in time.
MR. LOPEZ-SANTIAGO: Okay, thank you. So
let's move on to the next section of Construction
Inspection. We have a question for Nicole.
So, Nicole, with so much construction
going on and with inspection progress being hampered
by the pandemic, how can you be sure that NRC has
inspected what needs to be inspected to ensure that
the plant is being built safely?
MS. COOVERT: Thank you, Omar. And that's
a very good question, a very valid question for our
inspection group and our program.
So during the COVID-19 pandemic, our
inspection program kept track with Southern Nuclear
company's construction activities and at the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 36
time, we specifically prioritized, you know, our
inspections to one, focus on the mission critical
activities, but also through high transmission times,
prioritize our inspector safety and the safety of the
plant workers that we interface with.
So during the entire pandemic, this did
not change. We, our residents continue to connect
daily with the key on-site activities, such as: the
plan of the day, and work activities, pre-job briefs.
We also use both remote and on-site means
to implement the construction program. With that
focus of the nearing the 52 103g finding so we can
talk through inspections remotely from possible, but
during times the high transmission we specifically
reserve the onsite inspection for those critical
mostly activities which included directly observing
first of a kind AP1000 testing and significant test
activities that are typically only performed during
once in a lifetime the plant.
So some of the examples that we were on
site that's been specifically saw face to face and
observed during our inspections was the Unit 3, the
reactor vessel and reactor coolant system hydrostatic
tests. We saw the Unit 3 hot functional testing, the
containment structural integrity test and integrated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 37
leak rate test for containment for both Units 3 and
4.
And we also had inspectors on site to
observe installation of safety related items that
become inaccessible once construction is complete or
when the plant is operating.
So for example, we were onsite observing
the rebar installation and concrete placement for the
Unit 4 seismic Cat 1 structures, our containment and
But I will note that, you know, as I
discussed in the earlier section about these long
lead ITAAC, you know, we have done so many different
types of inspections over the years that, you know,
we have confidence in those activities that we've
inspected.
And when there are non-enforcement is
identified, then we build and inspect those as well.
But again, our inspections are not focused on one
specific activity, but we ensure that this mission
critical activities are observed. So hopefully that
answers your question. Thank you.
MR. LOPEZ-SANTIAGO: Thank you, Nicole.
Vic, what have you taken from the NRC's
transformation to be a risk-informed regulator for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 38
the construction inspection program?
MR. HALL: So and I don't mean to back us
any, Nicole had a good point. I want to key off of
it. I'll answer that question, but I'm, Nicole,
you're bringing back some really good memories of,
good relative memories of early on in the pandemic
and our discussions about how we keep our people safe
and, you know, what was going on at the site.
And I remember pretty early on, I think
Southern was one of the very first utilities to have
a massive testing facility outside of the plant.
And they were communicating their cases
so we were able to make a judgment call as to whether
it's safe for our folks. So you know, Nicole, we
sound like we're the same organization, but we
obviously have plenty of discussions and don't always
agree, but I've remember being incredibly impressed
with your side of the house when you're just making
sure our people were safe, but at the same time we're
also getting the job done to make sure that we're
looking at everything that we need to look at and
making sure our folks weren't in harm's way.
As far as transformation goes, Amy keyed
on data earlier on. And I like jumped, you probably
didn't notice it, but I like jumped on chair when she NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 39
did it because that has been to me, we're in the
information age, the biggest ability for us to think
differently about how we do what we do.
We developed a construction inspection
program, you know, over the course of a decade, with
an idea of how construction's going to play out in
the first of our Part 52.
And, of course, it's not going to be
exactly as you design it. Right? It's just there's
no working so we're not going to be able to design it
perfectly.
So being able to look back now at several
years of experience and using that data to look at
where we can be more efficient, where have we seen
enough of certain activities when it comes to looking
at ITAAC and really, you know, spend our time in the
right places has been for me, eye opening.
We build a dash board relatively early on
in the Vogtle project where we just gathered up
everything we could. I mean, what we build our time
for hours and what our cultural, what our specialties
were we were using and that was to me key and just
eye opening.
Plus, going down the regions and just,
hey guys, here's what we got data wise. You know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 40
where can we work together to adjust our inspection
program and what are you seeing as inspectors as the
key places to go.
So to me, transformation has been just
this wonderful use of data to be able to tailor our
program and be more efficient.
MR. LOPEZ-SANTIAGO: Thank you, Vic. We
have a question for Nicole. Nicole, can you explain
more specifically the remote inspections of ITAAC
versus completion on site? How does remote
inspection of ITAAC work?
MS. COOVERT: Okay, thank you, Omar. Well
essentially as the definition or of the acronym,
ITAAC, it's Inspection Tests, Analyses and Acceptance
Criteria, so those all have different functions and
abilities to inspect those areas.
So inspections can be done either onsite,
they can be done remotely, but definitely the testing
or the acceptance criteria and analysis is all prime
candidates for remote activity, remote inspections,
because as Amy said and Zach said, some of these
documents are thousands of pages.
And that's just one document that support
a closure of an ITAAC. So you know, there are
definitely opportunities to do remote inspections.
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We actually, before the pandemic, there
was, you know we had big team inspections. We would
have a one-week off-site inspection looking at this
documentation and then we would have on-site
inspections as well.
So that's no different than we did before
the pandemic. To handle the specific inspections
that we wanted to do during the pandemic to observe
testing or their inspection activity, then we would
be very deliberate that we'd send folks on site to
see those activities, we'd coordinate with the
licensee when this event was specifically going to
happen so there was no compromise to our inspection
program where we missed opportunities. We just did
it differently.
MR. LOPEZ-SANTIAGO: Thank you, Nicole.
Amy, from Southern's perspective, can you tell us
about the NRC's findings on cable separation?
MS. CHAMBERLAIN: Yes. So we take these
findings very seriously. We've taken corrective
actions in the instances of separation
nonconformances and we put measures in place to
present reoccurrence going forward as we complete
construction, remain focused on safety and quality as
our top priorities.
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MR. LOPEZ-SANTIAGO: Okay, thank you,
Amy. Now this question is for Zach. Zach, from a
design authority perspective, what are the key
processes you have implemented to ensure the
constructive plant aligns with the design and
licensing basis?
MR. HARPER: Yes, well this is a good
question. This is probably as far as to lessons
learned, this would probably be the number one. And
I think that so I guess a little bit of background.
When we had initially, you know when
Southern received their design or their construction
or their combined operating license in the 2012
timeframe, within I would say like one or two months,
we started to identify at site there were things being
implemented at the field that were not in alignment
with the license so we had, you know, paused to take
a close look.
And I think and at that point, we began
to implement changes within the Westinghouse process
to ensure that the design aligns with what's actually
constructed at the constructed plant.
So and we really haven't had significant
issues, you know, after those big changes were
implemented. And so what could we do, so what we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 43
really didn't have the benefit of any NEI 96-07,
Appendix D at that time, because it wasn't written,
it was written after our lessons?
The, what we, the primary thing is we
established a licensing basis review for every
document that was developed and you can imagine how
many documents that we create, we perform a licensing
basis and back determination to confirm that document
aligns with the applicable FSAR so the Vogtle FSAR
and the other licensing documents.
And there's, we developed a very robust
procedure qualification program for people that are
developing documentation, qualification program for
people that are identifying non-conformances at site
and reviewing those non-conformances and really a
culture shift to ensuring like what Amy had said
earlier verbatim compliance to the license and making
sure that we're meeting every word that is said.
We've done other things as well. We've
done compliance reviews. We've taken certain scopes
of work, we've picked, you know, the commodities
within the plant (inaudible) to check to make sure
that they're within the bounds of the license.
So what we did in terms of passing the
lessons learned, when we wrote NEI 9607 Appendix C, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 44
in Section I think 411, we added, you know, basically
a sentence, a few sentences in there that says during
the construction period, you know, you document your
basis for no impact of the license as you go along.
So that was kind of our attempt at passing
those lessons to others in the industry and it, you
know, I think it's important, you know, to pass those
and the other is really what I said before is the
verbatim compliance making sure that when we wrote
the design certification, it seemed like a good idea
at the time to write, you know, ambiguous statements
like generally or this is representative, but and
that was a good idea at the time because we thought,
oh this is going to give us wiggle room as we go
forward.
And as it turns out, it's really
difficult to inspect to that type of language and so
throughout the construction, a lot of the changes
that we actually made are not necessarily design
changes, they are changes to improve the clarity of
the license, to very clearly state what we are going
to do.
Because there's a lot of detail in there,
but even with that said, it was, you know, loading
that license with the variances that you're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 45
take and, in some cases, getting NRC approval to do
that when we were required to was a very important
lesson for us.
And you know, those that work in
Westinghouse on the AP1000 it's really a culture.
Does what you're doing comply with a license? And
it's a question that, you know, our group receives a
lot of questions every day on that questioning
attitude, hey, can I do this, can I do that?
And when necessary, we get Amy's team
involved and to make sure that they're comfortable
with those decisions.
MR. LOPEZ-SANTIAGO: Okay, thank you,
Zach. And we have one more question for Vic and
Nicole. Okay, sorry, right. So would the NRC
establish a singular branch or office like DCO or VPO
during the construction of future SMR projects, small
modular reactor projects?
MR. HALL: So Nicole, you can jump in
too, but I hope so because I think the combination of
VPO and DCO has worked well. You know, as we start
putting a lot of lists together, I'm sure we'll do
the environmental scan to see what the future of the
power looks like and put together the right type of
organizations that combine the expertise whether it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 46
ITAAC or whether it's Part 50 based plant with the
inspection staff.
Again, I think that looking at the
success we've had really with the VRG gives Vogtle a
written script which brought together all different
parts of the Agency.
I thinks that's, you know, that's just
almost a common sense recommendation of how we put it
together so I think well have to wait and see out
there and I think we've just got to sort our
application scenarios right now.
And NuScale, has their certified design,
but I'm sure NRC managers will be looking very hard
at what's the right organizational structure for when
we're ready for construction inspection plans.
MS. COOVERT: And I can't agree with you
more, Vic, because, you know, one of the key lessons
learned and I know that's the next topic, but the
Vogtle readiness group really was a part as a
fantastic lessons learned from Watts Bar that we were
able to not only communicate inspection licensing
issues, but we were also looking at, you know, the
logistics so to speak or the budget or staffing of
all of these different activities so it's a very solid
structure on how to look at those different aspects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 47
of an inspection program and oversight program.
And we, the one note I would say is that,
you know, whatever the organization looks like, we
have in this panel we have a senior manager nuclear
from the NRC, Mr. Omar Lopez.
He is our champion for the small modular
reactor program so I know that we will get the DCO,
the Division of Construction Oversight lessons
learned into what that project looks like in the
future.
MR. LOPEZ-SANTIAGO: Thank you very much.
Before we move on to the next section, there's a
question here, Nicole, for you. How would ITAAC work
if the majority of the advance reactors would be
manufactured off site and would start with minimal
on-site construction?
MS. COOVERT: So that's a great question.
And that goes, that model is exactly what we did for
the AP1000 that the vendor inspectors which went to
facilities all over the world were key inspection
attributes for completing ITAAC.
So whether it's done on site, it's done
in a fabrication shop, all of them are verified to
have the nuclear standards for appropriate quality
assurance program and they're inspected with all of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 48
the rigor that an on-site inspection would perform as
well. So it would be the same model.
MR. HALL: And Nicole, you're bringing
back good memories. And before I used to wear ties,
I wore a Polo shirt and hardhat, and I remember I got
a chance with the vendor inspection staff to travel
to Korea.
We watched the pouring of the ignot unit,
that piece just lump of metal that eventually formed
the reactor vessel and so we have inspectors who are
able to go all over the world and inspect these
vendors that are building plants.
I do think that we will have to think a
little differently about other plants. I mean, it's
going to be a different model versus, it's likely to
be a different model versus these large construction
sites on site so, you know, I have something we're
looking at too and I think we'll have to be times in
a changing world and how we can best adapt to that.
MS. COOVERT: Yes, I absolutely agree
with you, Vic. And we have other types of facilities
like the field facilities, you know, that we can
leverage lessons learned from multiple business
lines, not just construction reactors or operating
reactor business lines.
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MR. HALL: Good.
MR. LOPEZ-SANTIAGO: One more question
for Nicole. Nicole, has the NRC considered
incorporating regulatory office site guidelines to
supplement the reactor off-site process and then
begin termination process to help to remove ITAAC
from some other nonsignificant interest?
MS. COOVERT: Okay. That's, I will, I
want to call my friend, Mr. Vic Hall, because what we
do is for both the inspection process and the
oversight, the program office, we are continuously
reviewing our procedures, our manual chapters to
ensure that they're not only risk informed, but when
we come across lessons learned, that we are
absolutely discussing them, how do we incorporate
them, real time.
So we're not waiting for the next project
to make changes to inspection program. Vic, anything
else you want to add to that?
MR. HALL: Yes, I'm sure we'll talk about
this a little bit more. We talked to this concern,
but we are a learning organization that's always
looking to get better.
You know as I heard Amy and Zach talking
earlier about the compliance versus safety, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 50
again, an ITAAC war story here, and you know, I think
we're painting a picture of everything being rosy,
but not everything has worked perfectly.
And one of my least favorite ITAAC
stories was I got a call, Amy, or from one of your
colleagues was working on ITAAC, said Hey, we got
there's an ITAAC, this was very specific because we
need to test our tanks of water.
And to test them, you can either fill
them with nitrogen because the ITAAC very
specifically says test them by filling with nitrogen
air.
Now they said that, because in what
plants operate to fill with nitrogen, 100 percent
nitrogen, but to test them, you could use anything.
You could use any kind of gas. It would not change
the flow with the acceptance criteria.
And the question is well, can we just use
air which actually is 70 something percent something
nitrogen anyway. And you know, it was a tough call
and legally, the language of the law of compliance
said now it's got to be nitrogen.
You know, we would be relatively easy
license now, but you're talking about time to do that.
And in the construction environment, that's just not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 51
a realistic so I know the folks at Southern had to go
find tanks of nitrogen because to fill this reactor
full of nitrogen to comply with the letter of the law
for the ITAAC language.
And that was a shame. To me that was
okay, a good lesson that could be learned there. What
we really should be focusing on safety versus just
the compliance. Again, if someone did the right
thing, we were you know, it was the letter of the
law.
It was Tier I information so it was
relatively unbendable, but it pointed to again,
certainly if you look forward to writing ITAAC
language, to be more realistic and just to get a
takeaway learned from the last year of construction,
I think we can make improvements.
And so along those lines, you know, I
think we're always looking to improve our guidelines
for the reactor process for the significant
determination process.
So we're always looking to improve and
looking for feedback there as well.
MR. LOPEZ-SANTIAGO: Okay, thank you,
Vic. Let's go to the last section. Applying lessons
learned to an advanced reactor and future NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 52
applications. This question is for Amy. Amy, what
should the NRC do differently if when we have another
reactor construction project?
MS. CHAMBERLAIN: Differently? I think
we have to look at what we've done, well in this, in
what we've done for three and four. I mean, the
communication, the VRGs we've already mentioned
those.
Those are the key features that need to
keep those communication lines open with the NRC. I
know when I first came on about eight years ago, there
were some lines open, but maybe they are not anything
like what we have today that we've built and we've
added to over time. So I think those would, the key
features to keep moving forward we kind of touched
along the CROP, the inspection process.
I think there's further opportunity for
that are informed. That process and then I think we
have more lessons we are going to learn as we come,
as three and four comes online.
A particular focus for me is how is Tier
I going to affect us as we are operating? So those
would be key things I think, lessons learned, things
that the NRC should consider going forward.
MR. LOPEZ-SANTIAGO: Anything from you, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 53
Zach?
MR. HARPER: Well I agree with Amy. I
think that a lot the struggles and towards the
beginning of the project they have since been
resolved with really good communication.
And I think that, you know, carrying that
and they've been implemented it's like, so I think
that the process that we have now, today and with the
open lines of communication with the headquarters
organization and with Region II, the onsite
inspectors I think that is what really needs to be
taken forward.
MR. LOPEZ-SANTIAGO: Thank you. This
question is for Vic and Nicole. What advice would
you give your NRC colleague who are building a
construction inspection program for advanced
reactors?
MR. HALL: You went first, is it okay, if
I start this one first?
MS. COOVERT: Go ahead, Vic.
MR. HALL: I just volunteer. Sorry. No,
that's a great question. Everyone's obviously
interested in what's going to happen with advance
reactors.
I know that some motions use a director NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 54
in venue and they are working on what is a pretty
fascinating and very interesting framework for Part
- 53. Which was meant to take us forward for advance
reactors.
You know, from what I've seen from them,
it's been again, just really, really cool work and
it's Vogtle's right, I'm proposing that Vogtle is the
best project in the world.
But looking forward to some very
interesting stuff and so again you're building a
relative structure that's going to work for many
different technologies, and you know, I think, I know
for a fact that they've been taking their all lessons
learned from what we've done in the past.
And we will be putting together lessons
learned for this project as well which, you know, I'm
looking forward to sharing with them and then helping
them develop the program.
I do want to give applaud for our lessons
learned because I know that we saw our behind-the-
scenes stuff, special moderator Jim Gaslevic is
leading our effort to put together our lessons
learned effort from this stage of Part 52.
Our goal is once the thing is online,
103g, we have behind-the-scenes the first 52.103g, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 55
we're looking at having public meetings and gathering
more feedback and really capturing, especially
capturing these lessons learned from the last few
years just to get, to see different what is going
well, what may improve and help that team in the
future for advance reactors.
MS. COOVERT: Yes, and the only thing I
would add to Vic's perspective, is I agree with
everything that he said, is that the one definite
recommendation is the communication as Zach and Amy
both said.
Having those open, direct understanding
each other and your communication styles, you know,
that's very important to get through if you want to
be efficient and effective getting through some of
these complicated issues, that's when you really
challenge your communication and your working status
because they can get very difficult.
And so establishing open communications
very is a key lesson learned from the very beginning.
Also having, I would recommend a VRG like
organization within the NRC and the benefit of that
is you're having key senior managers across the
Agency that you can leverage and resolve issues in a
very timely manner or get the resources to do so.
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So that was when we restarted that up
after Watts Bar, that was a, it really quickly
promoted a faster resolution of some of these issues.
For an inspection standpoint, I would say
that, you know, continue to have a formal oversight
process that allows repeatability, consistency, you
have a defined methodology of how you're doing
inspections, you understand what your inspection
scope is and when it's complete.
And then big picture, I would say
organizational flexibility and agility. You know,
with different things happening in the industry, with
VC summer, when that situation occurred and just the
different challenges you face, including COVID.
You really have to have an organization
that can turn on a dime and still keep safety its
number one focus. So those are the recommendations
I would have the lessons learned.
MR. LOPEZ-SANTIAGO: Thank you. So
before we go to the next question, Vic, I have a
follow up for you. You mentioned that the VPO office
which is sponsoring a lessons learned effort for the
Vogtle Project 3 and 4. How do you plan to engage
the public so you can get their input?
MR. HALL: Thanks, Omar. We are planning NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 57
public meetings. What's kind of nice about the
virtual world is it's so a lot easier to gather folks
from all around the world really to meet in forums
like this so if there is a silver-lining to the
pandemic, it's these kind of use of technologies.
But I think in everything we do, we are
trying to get as much feedback from all stakeholders.
And so for the lessons learned, absolutely, we will
be looking to again, engage the public, engage all of
our stakeholders and, you know, I'd like to hear the
criticism.
I want to hear where we could have done
better. And feed those awesome again for the future.
Because again, I think we've done great work, but
we're humans and we are a learning organization
committed to getting better and learning.
So absolutely, there will be follow up on
lessons learned. And I will say one more thing when
it comes to communications. You know, we're not the
IRS, you can call us, you don't get a recorded line.
If you email or call us, you're getting
a person and so if you have questions, if you want to
call up, if you have things you want to feed us before
hand, you have my email, you have Omar's email
address, you have Nicole's email address and phone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 58
numbers.
Reach out to us anytime because we do
want to hear back. We do want to hear from as many
possible stakeholders and we do want to engage as
many people as possible.
Again, the more opinions you get, the
more diverse gift thought we get the better we will
be in the future.
MR. LOPEZ-SANTIAGO: Thank you, Vic. We
have a question for Zach. Zach, how much did having
a reference combined operating license help licensing
and construction of Vogtle or it did not help?
MR. HARPER: Well, I think it did help.
The, so take back in time, there's a design center
working group that was made up of, you know, TVA,
Southern Nuclear, Scania, (inaudible) there was Duke,
what progress at the time.
And they made up a group and the RCOLA
originally was Belafonte. It transitioned to Vogtle
maybe the 2008 timeframeish. But ultimately what
that group did and they partnered -- there's another
organization called New Start and really what they
were doing is establishing what a Part 52 license
would look like and what those RCOLA applications
would look like, so.
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And the reference kind of set the
standard, it set, you know, what everyone else
followed and that just contributed to you know, the
standardization of the plant.
Because when all the words in the
licensing basis are the same, then you know, you have
one issue, one solution, one implementation into
multiple plants.
So I think that you know that process,
what happened with New Start and you know, part of
what they were doing was they were closing COL
information items.
It's like certain information items are
things that specified in the DCD requirements to a
COL that need to be closed. And they were developing
plans for closure and some plans closure would be
hey, Westinghouse, go do this work and some cases it
would be some site-specific evaluation.
Others it would be ways that could be
addressed by a licensee in a standard way in the same.
And so I think that RCOLA process was helpful in
bringing the licenses, moving the ball forward,
moving the licenses through the RCOLA application to
a COL.
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being built. But even still, I still think it was an
advantage having all of those utilities involved
because frankly there was not a Part 52 license
before. There wasn't a COL that had intended to
build.
And having inputs from different
utilities into a standard way of submitting a license
I think was a big advantage because it, you know,
established an industry precedent for that
application that was ultimately approved and is being
constructed and will hopefully start soon.
MR. LOPEZ-SANTIAGO: Thank you, Zach. So
this question is for everybody here so. Given the
chance to go back in time, what would you do
differently? Let's start, who wants to start? Don't
make me pick. Okay, let's go with Amy.
MS. CHAMERLAIN: Thats a great question.
Let me think about it for a minute.
MR. HARPER: Do you --
MS. CHAMBERLAIN: I'll --
MR. HARPER: -- do you want me to --
MS. CHAMBERLAIN: I'll go and, you know,
I'll be honest, my rule of thought is licensing. You
know, that's where I think and I think I'd go back to
the verbatim compliance and what Zach mentioned on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 61
how many changes we needed to make and not just ones
that required NRC approval, but the departures that
we made through our own 50.59 like process that we
had to provide so much clarification in the FSAR to
allow for construction, to allow for inspectibility.
I think if I had it to do over again,
with all the knowledge I have now, is to go back to
those days. You know it's easier to do something
right, you know, do it once, I tell my kids all the
time, you know, it's better to do it right once than
having to go back and do it again.
And so that would be the only that, not
the only thing, but I think that'd be the major thing
that I'd go back and do is look at the DCD and Vogtle
3 and 4's COL application from in that light. Zach,
did you want to add?
MR. HARPER: Well, I agree with you. I
think that that's good. What, not to repeat what you
said, I would also bring up the, I think the
implementation of Tier II star, you know, if I had to
go back and do it all over and give someone, you know,
tell someone the future I would talk to them about
Tier II star. I don't think that part of the
regulation was necessary.
I think that we could have done other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 62
things in the license. You know, since that time
we've implemented, you know, certain criteria or
Southern has impletmented certain criteria in their
COL to address that, but you know, if I could go back
in time, then Tier II star would be at the top of the
list to either identify those requirements, put them
in an ITAAC somehow or identify those requirements
and say hey, this is just like an FSAR.
We have to comply with the FSAR no matter
what. It's, you know, a Tier II star requirement in
terms compliance, what's actually put in it's final
resting place, you know we're required to follow that
just as much as we are to follow words in the FSAR.
And you know we can, the industry has
demonstrated the use of 50.59 for years safely,
across the industry through the operating plants and,
you know, I think that was probably a bigger lesson
learned that has been implemented in several of the
new, the more recent design certifications where they
dont have that.
So I am happy to see that others have
been able to take advantage of that lesson.
MR. LOPEZ-SANTIAGO: I'm sorry, very,
very, high level. Will you explain what Tier II star
is for the audience that might not know.
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MR. HARPER: Oh, sure. So in a design
certification, there's two tiers, there's Tier I
which is made up of mostly the ITAAC, there's some
other information, but that any time you change,
touch anything in Tier I, it requires the NRC's prior
approval.
The, in Tier II that's what a traditional
operating plant's final safety evaluation report
looks like. It has the same structure, it follows
the Reg Guide 1.70 format.
And you know, there's provisions within
50.59 that allow you to make, that allow utility to
make changes without prior NRC approval.
Within Part 52 however, there's an
additional criteria that was added to the design
certification rules that information that is
bracketed and italicized and has a little star next
to it requires NRC approval to change.
So that, at a high level, that's really
it's information that a traditional operating Part 50
plant would be able to make changes to without NRC
approval, it's for you know, for Part 52 plants that
information requires it.
MR. LOPEZ-SANTIAGO: Okay. Thank you.
Nicole, you want to go next?
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MS. COOVERT: Sure, the one thing I would
note in looking, if I could go back in time, is I
would look at a possible more flexible inspection
program.
And I say that because we created from
the construction reactor oversight process, we have
as I talked about earlier, we have manual chapters
that have and inspection procedures and that
framework is outstanding.
In really looking at types of inspections
so that you have a good broad regulatory breadth of
inspections that happened over this huge project.
In developing those, we also made
inspection plans that in some times and in some cases,
were very restrictive and didn't allow us the
flexibility that we have since incorporated into our
program.
And I say that because the benefit we had
and the foresight we were having at the time was, I
mean, I believe the renaissance was happening, we
needed to be prepared for multiple new construction
projects, all in different phases.
So it was very important to have that
kind of rigor and structure. But as we worked through
Vogtle's inspections sometimes we found areas that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 65
could make improvement and changes.
And so Vic had referenced it earlier in
this discussion that we worked with VPO several years
ago and we went and we essentially looked at every
single activity that we've done to date, the hours,
inspection hours, we have done in certain areas,
functional areas, types of valves, welding,
companies.
And so we were able to go back and say
put some more flexibility into our program because we
did that assessment. So again, Vic said it perfectly.
We're a learning organization, we've
never going to be perfect, but we, if we have that
mindset to keep looking forward, we're not stuck in
something that's not flexible or agile, but that is
the recommendation I would make if I was going back
in time.
MR LOPEZ-SANTIAGO: Thank you. Vic, what
do you have for us?
MR. HALL: There's so many things I would
change if I could go back and I probably wouldn't
have as much grey hair. You know what I'm saying?
There are a lot of nuggets today.
I think just ideas that talk about the
history of how things were developed and Zach, when NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 66
you talked about targeting of ITAAC and I still
remember early discussions when we were talking about
should we have a public list of targeted ITAAC and
how you balance that idea of independence into being
offering clarity and then openness to what we were
going to inspect so adding in every area there's
things I'd love to go back to and change.
But I think along the way, we've
appropriated all of those lessons, but I think we've
tried along the way to improve along the way so I
appreciate the comments on Tier II star. I know
that's been a sore point.
Certainly, the idea of this compliance
versus safety and looking at the language of the
ITAAC, boy if I could go back and re-write some of
those ITAAC, I'd love to because I think there's
certainly room for improvement in those.
But having said that, I think we've done
an admirable job, again you know, making the magic
happen, making safety come through these words that
other humans have to understand so I'm proud of what
we've done, I know that there are plenty of things
that we can improve from and I'm looking forward to
making a better safe nuclear industry.
MR. LOPEZ-SANTIAGO: Thank you, Vic. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 67
from the conversation this morning, I have heard the
following things, for example, communications. From
communication and frequent communication is very
important to ensure that all the stakeholders are on
the same page and to avoid problems down the road.
Also, we heard that when you're
developing your design certification, your license,
your ITAAC, it's very important to make sure like
you're very specific and you're clear to avoid
confusion down the road because every person has a,
will have a different many interpretations of what
you originally intended to write.
So anything before closing, anything else
that you guys would recommend or give any advice to
the people that are trying to put in place new advance
reactors?
And we have four minutes. If you were
King for the day, what would you change?
MR. HALL: I'll have to say, the folks
that have joined today and the last day of the RIC is
usually the tough point in that people are tuned out
from all of the speeches so if you're on the call
today and you're listening, you are probably way
ahead of the game than you're understanding of
nuclear processes and your interest in the Part 52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 68
and everything else so you know I thank you for
listening certainly today.
Again I would welcome or invite you to
stay engaged, to give us a call if you have questions
on what you heard today and talk more because I think
it's important to keep dialogue going.
Communication is going to be across
everything. And we talked a lot about communication.
We're doing a lot about that, it's being deliberate
about how you communicate, in such a manner as I
understand, I'm going to talk more, I'm going to have
more meetings.
Gosh no one wants more meetings, but it,
I think we've been very deliberate in structuring who
will bring it in, how we're bringing folks in, making
sure engaging the public.
I know we've had Vogtle witness groups
down near the site to make sure we're able to reach
the local communities which is just, you know,
critically important for what we do in the NRC so
being deliberate and moving forward is going to be
key.
MR. LOPEZ-SANTIAGO: Zach, you're on
mute, Zach.
MR. HARPER: Sorry. I don't think that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 69
I have any other really lessons learned for the
advance reactors. I think that you know, I think
that a lot of them are in their pre-application stages
at this point and I think that you know, they're in
there still developing their technology.
I would say that there is a lot of, you
know, I get a lot of questions on Part 52 and I think
that, you know, there are balances between Part 50
and Part 52.
You get the advantages of that signed
finality and you get the advantages of the
standardization and you get certainty and those
issues and all the issues resolved up front.
That's big advantages. The downsides is
that it can be challenging during construction to
make changes to that license because you have a
license.
And so as the plant is being constructed,
you don't want the delays and, you know don't want
the licensing process to cause delays.
So you know, it's really a balance on
what the advance reactors on what their strategy is,
their licensing strategy is going to be. And I think
that the challenges, building a nuclear reactor is
challenging no matter what.
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No matter what process you follow, Part
50, Part 52, Part 53, it's all going to be
challenging. There's not a process that's going to
make things just easy.
So but I think that some of the key
lessons that we talked about today apply regardless
of what process that we're following and you know, I
just thank everybody that stuck around at this point
for their time and I appreciate sharing with you.
MR. LOPEZ-SANTIAGO: Thank you, Zach.
Nicole, Amy, any last words?
MS. COOVERT: Again, I -- oh, go ahead,
Amy.
MS. CHAMBERLAIN: Just real quick. I
haven't said it and I almost always say it when I
talk to folks. If you look at Unit 4, we've applied
lessons learned on Unit 3 right to Unit 4 and so as
Zach said, standardization we have two plants next to
each other that we're building the same and we're
learning and applying it.
Things just go smoother on Unit 4 so I
think to future applicants, that is something you
should definitely, you know, look at that even though
Part 52 might be difficult at times to construct,
once you apply those lessons, you do gain a lot of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 71
benefits thankfully. Go ahead.
MR. LOPEZ-SANTIAGO: Thank you. Nicole?
MS. COOVERT: Yes, the only thing I would
add is that, you know, today you heard three different
independent perspectives. We all have our individual
roles in this, but I can tell you that from what you
heard today that every one of us, every position, our
number one focus is the safe construction and
operation of these nuclear power plants.
So, you know, that's a commonality that
we have even in our different independent rules.
Thanks, Omar.
MR. LOPEZ-SANTIAGO: Well, thank you all
of you for your participation and sharing your
thoughts of our lessons learned of implementing the
Part 52 for Vogtle 3 and 4. So that's all we have.
Thank you very much and have a great day.
(Whereupon, the above-entitled matter
went off the record at 10:01 a.m.)
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 www.nealrgross.com WASHINGTON, D.C. 20009-4309